|October 14, 2002|
From: Steve Weitz
Sent: Thursday, August 29, 2002 2:56 PM
Subject: Accessible Public ROW
Reference is made to your 8-27 email regarding proposed new standards. While
we generally try to address these issues while reconstructing streets, a couple
of the proposals stand out as particular concerns:
1. Audible Signals at all pushbuttons- A vendor recently quoted us over $4000 just for equipment at a 3-way intersection, exclusive of physical changes to the curbs/ ramps. Of our 60 signals (population only 60,000), we have only received requests for audible devices at a handful. The MUTCD indicates that these should only be necessary in certain conditions, such as high turn volumes or very low traffic volumes. Installing them everywhere, with additional ramps (we usually have only one at corners due to small radii & limited ROW) & relocation of equipment, etc, would cost from a half to one million dollars for relatively little demand. Also, we unfortunately get plenty of complaints from sighted pedestrians about aggressive & inattentive drivers running red signals or not yielding, so I don't see how we can provide a safe enough environment for those who are impaired just by installing audibles. Local groups train guide dogs in our CBD. Other than with dogs, white canes, or asking for assistance, how do the blind or severely impaired negotiate unsignalized intersections? Since those don't have the exclusive ped phases & No Turns on Red that many of our signalized locations do, presumably some or many may be more difficult to negotiate than the signalized ones. Will we next be asked to signalize them for this reason? As with all other transportation investments, there needs to be a cost-benefit consideration. While these may be desirable at certain locations, a universal requirement does not seem appropriate.
2. One Accessible Space per blockface- Some blocks are long (would be an 'insufficient' number) & some are short (would be excessive percentage). Where off-street convenient handicapped parking is provided, that would seem to be preferable from a safety standpoint. CT law does not allow time limits on HC parking, so those on-street HC spaces we have tend to be taken for long time periods by employees, making them unavailable for HC customers anyway. Lastly, certain businesses (eg. drugstores) might have more of a demand than others, and businesses do close or relocate. I don't know the best way to address this, but there needs to be less federal mandate & more local judgement.
3. Ped Crossing Speed- As others seem to be commenting, reducing from 4 to 3 fps should be a local decision based on need/ demand. We have many exclusive pedestrian phases, which already take a high percentage of the signal cycle. Motorist delay caused by excessive crossing time tends to encourage more signal violations, which is a hazard to all pedestrians.
Please feel free to incorporate these thoughts into the formal statement. Thanks for soliciting our comments.
From: Dan Schiada
Sent: Thursday, September 05, 2002 9:27 PM
Subject: Draft guidelines from US Access Board
I want to provide my comments regarding the proposed standards to improve the pedestrian environment within public rights-of-way. I am the City Engineer from the City of Benicia, California. Our population is 28,000 and we are very proactive in providing for ADA access within our street rights-of-way to the maximum extent possible. However, I do share the concerns expressed by Daniel Centa from the City of Pueblo, CO. Many of the proposed requirements may have unintended consequences including my big concern that overly restrictive standards may actually delay the ability for small agencies to implement improvements. We only have a small amount budgeted each year for ADA improvements and mandated requirements for situations where they are not warranted (ped barriers, elevators, traffic signals, etc.) will result in no improvements being provided.
Some of my concerns include:
- The requirement to acquire right of way where "practicable" may force local agencies to abandon a worthy project rather than overcome this requirement.
- I do not see the reasoning for discouraging single ramp installations. At many intersections, there are two crosswalks that come to a single point at a corner. For this situation, it makes better sense to provide the single ramp. Also, at many signal locations, there is one push button pole to cross either direction and the single ramp would properly direct pedestrians to this one location.
- I don't understand the meaning of "changes in level shall be separated horizontally 30 inches minimum".
- The implication that curb ramps need to be parallel or perpendicular should be eliminated. The ramp needs to properly direct pedestrians to the crosswalk direction which may or may not be perpendicular or parallel to the curb face.
- The requirement for detectable warnings should only be required for ramps that so flat that the sight impaired user cannot tell if they are on a ramp (slopes of 1:15 or less).
- All requirements should conform to existing MUTCD standards .
- The requirement for a maximum cross slop of 1:48 at intersections is not feasible and would create drainage and rideability problems. . Also, there are numerous locations within Benicia where our street centerline slopes exceed 10% and meeting this requirement is not feasible.
- The current 4 feet per second standard for pedestrian signal timing has been in place for many years. Changing this to a 3 feet per second standard will create major delays at congested intersections resulting in increased accident potential for both pedestrians and vehicles. I see no justification for this change. There should be consideration for requiring that the timing for pedestrians (using the 4 ft/sec standard) provide for a complete crossing from one side of the street to the other. Currently, in California, the ped clearance interval needs only to provide time for the pedestrian to reach the center of the farthest travel lane.
- The pedestrian overpass requirement is unreasonable. The ramps should only need to conform to the standard ADA ramps requirements with level resting platforms at appropriate intervals.
- The requirement for signalization at every roundabout and slip lane is unreasonable. These situations are no different than numerous uncontrolled crosswalk locations. Each situation needs to be evaluated on its one. The overall blanket requirement is onerous.
- The requirement for specialized tactile ped signal systems is unreasonable. Our standard buttons are appropriate for most locations. If there is a special situation, then this should be up to the individual agency to determine when these specialized devices would be appropriate. The blanket requirement is onerous.
- The City of Benicia does have a downtown business district that relies on on-street public parking. We have provided handicap parking spaces at selected locations using common sense in determining their locations. Spacing, proximity to public facilities, access to the main pedestrian activity areas are all critical issues that we evaluate to determine the most appropriate handicap space locations. Also we can easily change locations as uses change, activity centers change and as handicap needs change for each location. We use the parking lot standards as our guide to determine the number of handicap stalls we will need. It is NOT reasonable nor is it appropriate to just place standard requirements of one space per block and provide 5 foot indents. The number of spaces should follow the same guidelines as for private parking lots. Also, there are many street locations that do not have the room to provide the 5 foot indent. These handicap spaces are accessible without the 5 foot indent. If the concern is safety with through traffic, this situation exists for every parking space and it is taken into account when laying out the parking without having to arbitrarily resort to installing 5 foot indents for every parking space.
- The five foot indent for loading zones is also not appropriate as a blanket restriction. Every loading zone we install does look at pedestrian safety whether or not it is handicapped.
- The requirement to install an alternate path is great, however, to mandate that it be on the same side of the street may not always be possible. For Benicia, we have very short blocks (350') and there are times when we need to close off the entire side of a street to accommodate a construction project. Proper signage, ramps, etc to the other side of the street is sometimes the only option.
Thank you for allowing me to provide comments to this very important issue. We continue to support the concept of reasonable accommodation for ADA accessability and hope that these comments will be taken in the spirit for which they are intended.
Draft Guidelines for Accessible Public Rights-of-Way
Comments by City of Bellevue, Washington
Additions and Alterations – Guidance for additions and alterations is the scope of the project would determine the extent to which the guidelines apply. Also, compliance would be required except where “technically infeasible”. Practically anything is “technically feasible”, as long as sufficient resources are committed. The example of a bridge column could be solved by rebuilding the bridge, which is “technically” but perhaps not “fiscally” feasible. Perhaps this guideline should be given in terms of fiscal impact. As currently written, these statements are somewhat vague and could lead to broadly different interpretations.
Alternate Circulation Route – We agree that it is desirable to provide alternate pedestrian routes during construction. However, it is not always practical or financially feasible. Guidance regarding exceptions should be included, particularly when providing an alternate route results in a cost that would prevent the project from occurring at all, or where the construction duration is extended such that this extension has more disbenefit than not having an alternate route.
Diagonal Curb Ramps – We have used diagonal curb ramps with apparent success and no complaints from the public. They have advantages in some cases, such as lower turn speed across the crosswalk, better sight distance to the pedestrian, more full height curb around the corner radius, ease of crosswalk layout, and better ability to incorporate junction boxes, storm drains, etc. Detectable warnings help address the concerns of the committee. The advantages of this type of ramp should be acknowledged. The strong statements against their use could be used against an agency when this treatment is selected for use, whatever the reason.
Perpendicular Curb Ramps - The same exception for slopes at mid-block crossings should be given at intersections. The curb ramp slopes for the side flares (1:10) and cross slope (1:48) should be measured relative to the running slope of the sidewalk, not level. Leveling entire intersection areas is not reasonable or practical in most cases.
Parallel Curb Ramps – Again, the same exception for slopes given at mid-block crossings should be given at intersections. Running parallel ramps out 15 feet may not be desirable or reasonably feasible, and could have unintended concerns.
Detectable Warnings – The ramp between sidewalk and crosswalk should provide adequate notification of the blend of a pedestrian way with a vehicular way. Truncated domes should only be required where ramp slopes are very gradual; 1:15 or less as suggested by Pueblo seems reasonable.
Other Curb Ramp Requirements – It is often very difficult, especially in developed urban areas, to avoid conflicts between curb ramps and utility fixtures. Relocating utility fixtures is not always a reasonable option. Recognition of this including some allowance and guidelines for integrating the two should be considered. For instance, placing junction boxes wholly within the ramp (instead of the side flares) when necessary.
Crosswalks – Limiting cross slope to 2% will require “tabletop” intersections, which may not be reasonable to construct, particularly in areas with challenging topography and/or limited rights of way.
Pedestrian Refuge Islands – Although the 6 foot minimum length is desirable, it could prevent the installation of a refuge island altogether where space or right of way limits the refuge to less than 6 feet. Engineering and site specific conditions should determine if a refuge island less than 6 feet long should be installed.
Pedestrian Signs – There could be conflicts between the minimum and maximum mounting heights specified in 703 and the minimum mounting height of signs specified in the MUTCD, particularly for stand alone signs. Availability of space and location for all the required pedestrian signs is also a concern.
Pedestrian Overpasses and Underpasses – The construction and maintenance cost of elevators will significantly reduce the actual installation of overpasses/underpasses when this type of structure is the best solution. The installation of resting platforms, where reasonable, is a better approach.
Roundabouts – The requirement to signalize the pedestrian crossings at the splitter islands is not sound, reasonable, or consistent. These crossings are essentially mid-block crossings; however, signalization is not required at other mid-block crossings. The requirements to signalize roundabout pedestrian crossings will limit the use of what is proving to be an intersection control strategy that works well for a number of situations. The decision whether or not to signalize roundabout pedestrian crossings should be determined during project engineering based on all the conditions associated with the intersection.
Further, a continuous barrier should not be required. Accessibility requirements are moving toward ramps or detectable warnings at crossing locations. The outside of the circulating roadway is typically curbed with sidewalk behind. The curb drop off is reasonable notification to the pedestrian of where the sidewalk ends and the circulating roadway begins.
Turn Lanes at Intersections – Slip right or left turn lanes have proven to be useful features in intersection design. They can provide shorter pedestrian crossings, better channelization at skewed intersections, reduced open pavement space, and stopped vehicle refuge at intersections. They can also increase intersection capacity. The requirement to signalize pedestrian crossings across these types of lanes is not sound or reasonable. These types of lanes are often found at unsignalized intersections; a requirement to signalize just the pedestrian crossing portion of the otherwise unsignalized intersection is not reasonable and eliminates engineering from the design process. The only time signalization of the pedestrian crossing across a slip lane should be required to be considered is at an already signalized intersection, with final determination during design engineering of the intersection.
Stairs – This section should be clarified to exclude existing, limited use stairways. A common example is a stairway from an existing house to a street. Often these types of stairways must be modified to match a new sidewalk installation along the street. It is not reasonable or necessary to meet the requirements of 504, particularly when the residence does not have special accessibility needs.
Handrails – This section should be clarified to not include pedestrian railings intended to protect pedestrians and cyclists from drop-offs at the back of sidewalks.
On Street Parking – Handicap spaces should not be required in residential areas. Parking is typically widely available in these areas, and parking areas are generally unmarked. Handicap spaces should be marked by the jurisdiction only upon the request of a resident, and only when parking is not widely available. Further, the requirement of a 5’ indent on new residential developments would not necessarily be in character with the goals of the developer, residents, or jurisdiction. This is especially true when the location of these indents would be random and not necessarily adjacent to any handicap residents that might happen to move into the development. Also, it would be reasonable to assume the parking needs of these residents could be met in their own driveway.
In commercial areas, handicap stalls are required on the business site, and should not necessarily be required on street. Installation of handicap stalls on street would be better handled on a flexible, case by case basis. The requirement of an access aisle for parallel spaces is very problematic, particularly in areas of “zero setback” buildings. Taking from the sidewalk space, when the sidewalk width has been established based on forecasted pedestrian demand, is not reasonable.
Other concerns include on-street parking spaces that are time of day (sometimes parking allowed, other times the lane is used for traffic). Individual stalls can not be marked in these types of lanes.
Passenger Loading Zones – The aisle width requirement is again problematic per discussion above.
Pedestrian Signal Phase Timing- The use of 3.0 ft/sec may have many consequences for overall intersection capacity/safety that are not necessary or good engineering. The State of Washington is a permissive state. A pedestrian entering the intersection legally has the right of way and other vehicles must yield until they clear the intersection. Bellevue currently uses the 4 ft/sec national standard, but uses the full roadway width (typically) for determining phase clearance timing. If we use an 84’ crossing, as an example, at 4 ft/sec would require 21 seconds while 3 ft/sec would require 28 seconds. If the vehicle volumes can justify the extra 7 seconds no problem. However, in many cases this would require a longer cycle length or unnecessary delay to other users of the system. If we use the current national standard and only require the pedestrian to reach the middle of the far lane, this drops the required clearance to 26 seconds. If we allow the pedestrian to finish crossing at the same time the vehicles are finishing crossing (4 seconds yellow typical) this drops the required clearance to 22 seconds. We then have 1 second of All-red to clear the intersection. This shows we can provide clearance for someone traveling at 3 ft/sec, without taking into account the fact of how many pedestrians start their crossing at the exact time we start the clearance time. Bellevue typically has 7 seconds or more of walk time and in coordinated directions can have upwards of 40 to 50 seconds of walk time followed by a clearance. To increase the clearance requirements in light of these facts is not good policy. Many pedestrians who know they are slow walkers would not continue to cross an intersection that is 84’ wide if within one or two strides it is already flashing for clearance. We feel we have provided them safe passage (assuming drivers obey the law) even if they do choose to continue.
We can find no rational explanation for requiring the clearance interval to include another 12’ or 4 seconds so an individual can start/end 6’ behind the curb, especially considering the requirements for maximum curb ramp slopes at all intersections.
Another consequence that some areas under Air Quality restrictions from the EPA will face is whether to eliminate the crosswalks that vehicle traffic cannot justify the increased clearance time requirements. Many jurisdictions already have had to remove or choose not to install protected left turn phases, even though left turn delay or accident history warrants have been satisfied. This would actually decrease the mobility of the pedestrian at the intersection.
Accessible Pedestrian Signals- The blanket requirement for using an audible walk and vibrotactile device at all crossing is fiscally irresponsible and not supported by current research results from the disabled community. Bellevue has had an open policy of over 10 years to install the audible walk devices where requested. Of the current 165 signals under operation, only 14 locations have audible pedestrian devices. Electromechanical devices like the vibrotactile device require a much higher level of maintenance and are more likely to be vandalized (similar to push buttons) which further increases the fiscal impact and potential staffing requirements for numerous unnecessary installations. The current locations mostly agree with the latest research of intersections with complex phasing or high background and/or adjacent traffic noise. A location that is a simple 2 phase isolated intersection does not warrant the same investment that an 8+ phase intersection with overlaps warrants. We recommend a graduated requirement depending on the conditions actually present at the location and more dependence on working with the disabled community to determine where the problems are actually being experienced.
We know of many locations that if required to have the display within 5’ of the crosswalk and 10’ from other displays, would require one of the poles to be placed in the sidewalk and not behind the sidewalk. This would have the unintended consequence of placing on obstacle within the sidewalk. This requirement should be revised to guidance where specific conditions allow avoiding less than desirable installations.
A 2” chrome plunger protruding from a Black and White mounting bracket/Sign seemingly provides adequate contrast, and we are interested in further clarification.
Why would there be a requirement for tactile/visual street name signs on pedestrian crossing equipment, when it is not required at any other location. There doesn’t seem to be any uniformity or consistency of when/where many of these requirements are being implemented.
James Condry (8/8/02)
Daniel E. Centa, P.E. (8/21/02)
Andrew P. Avery, P.E., Sr. (8/29/02)
Stan Clauson, AICP, ASLA (9/17/02)
Ron Coontz (10/2/02)
Patrick G. Rivera (10/3/02)
Chad J. Smith, P.E. (9/30/02)
Lewis H. Garrison, P.E. (10/1/02)
Gene Putman, P.E., P.T.O.E (10/1/02)
John N. LaPlante, P.E., P.T.O.E. (10/14/02)
Lloyd E. Neal, P.E. (10/17/02)
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